Federal Income Taxation of Partners and Partnerships in a Nutshell


Book Description

This book provides a concise overview of federal partnership taxation. It covers partnership formation, including contributions of property and admission of service partners, allocation of income and loss, tax accounting, and sharing of recourse and nonrecourse liabilities. Building on this foundation, the book also addresses advanced topics, including transactions between partners and partnerships, sales of partnership interests, distributions of property, optional and mandatory basis adjustments, and planning for retirement or death of a partner. Numerous concrete examples illustrate the tax treatment of specific transactions, allowing students to grasp the principles of partnership taxation in a problem-oriented course. The revised edition reflects developments through September 2012, including codified economic substance doctrine and penalty provisions; choice of business form and classification of series entities; at-risk and passive loss rules as applied to LLCs and LLPs; partnership debt-equity exchanges and proposed carried interest legislation; new rules on accounting for partner's varying interests in the partnership; and disguised sale transactions and recent tax-shelter decisions.




Federal Income Taxation of Partners and Partnerships in a Nutshell


Book Description

Common Law and Equitable Remedies for Breach of Contract; Expectation Damages; Restitution; Reliance Damages; Specific Performance; Contracts for the Sale of Goods: Buyers' and Sellers' Remedies Under Article II of the UCC; Remedies Available to Buyer When He Has Not Accepted the Goods; Remedies Available to Buyer After He Has Accepted the Goods, Including Remedies for Breach of Warranty; Remedies Available to Seller When Buyer Defaults and Has Not Accepted the Goods; Remedies Available to Seller After Buyer has Accepted the Goods; Contractual Control Over Remedy; Liquidated Damages Clauses; Contractual Modification or Limitation of Remedy Under UCC 2-719; Remedies for Mistake and Unconscionability; Mistake in the Formation of an Agreement -- The Recission and Restitution Remedies; Mistake in Integration or Expression The Reformation Remedy: Mistake in Performance of an Obligation The Restitution Remedy; Unconscionability.










Partnership Taxation


Book Description

The book provides an Introduction to the federal income taxation of partners and partnerships. The first six chapters explain how the income of the partners is taxed, and how the law achieves its objective of disregarding the business entity and taxing the partners directly. Chapters one through three focus on the classification of business entities, the pass through of a partnership's tax items to partners of the partnership, and the concept of partnership capital accounts. Chapters four through six examine the questions of how the partnership's tax items must be allocated among the partners. Chapters seven through nine consider transfers of partnership interests, contributions to and distributions from partnerships, and potential recharacterization of these transactions. ten address the tax consequences of compensating partners for services and use of capital. Chapter eleven discusses partnership terminations. The last chapter explores special anti-abuse rules that limit opportunities for abuse of law.










Federal Income Taxation of Corporations and Partnerships


Book Description

A return to coverage of partnerships & limited liability companies highlights the Third Edition of FEDERAL INCOME TAXATION OF CORPORATIONS AND PARTNERSHIPS. With more of the extremely effective problems that gained it such widespread praise, this flexible casebook is now completely updated for use in a wide variety of course offerings. To simplify the intricacies of the taxation of business enterprises, the authors: use problems & examples in almost every chapter -in addition to cases & notes illustrate typical commercial transactions emphasize major themes of policy & practice keep the book flexible enough to be used in two-, three-, or four-credit courses offer an extensive Teacher's Manual FEDERAL INCOME TAXATION OF CORPORATIONS AND PARTNERSHIPS, Third Edition, is logically organized into three main parts: Corporations S Corporations Partnerships The Third Edition reflects recent developments in corporate & partnership taxation: 10 full chapters on partnership taxation including new materials that address the explosive growth of limited liability companies & hybrid entities new debt/equity limitations in corporate formations & reorganizations anti-abuse redemption provisions covering stock options & sales between related corporations the Anti-Morris Trust changes to tax-free spin-offs new elective classification regulations liberalization of Subchapter S shareholder restrictions & changes to timing of Subchapter S distributions, & Qualified Subchapter S Subsidiaries Give your students a firm foundation in the means & methods of corporate taxation & partnership today.